News & Analysis as of

Canada Revenue Agency (CRA) Goods and Services Tax

Stikeman Elliott LLP

Tax Court’s Denial of a Bank’s GST/HST Rebate Claims Affirmed; No Issue Estoppel as Retroactive GST/HST Legislation Had Been...

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This dispute arose when the Canada Revenue Agency (“CRA”) reassessed President’s Choice Bank (“PCB”) for uncollected GST/HST on bundled supplies made to a major Canadian bank (the “Bank”) and denied the Bank’s rebate claims...more

Stikeman Elliott LLP

New GST/HST Notice on Services Provided by Insurance Intermediaries

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In July 2023, the Canada Revenue Agency (“CRA”) released GST/HST Notice 325 (the “Notice”) with respect to services provided by certain insurance intermediaries. The Notice essentially makes official the 180-degree turn the...more

Stikeman Elliott LLP

Dental Crowns and GST/HST Credits: A Dentist Wants to Have His Cake and Eat it Too

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In an informal procedure decision, Axelrod v. The King, rendered on December 12, 2022, the Tax Court of Canada dismissed the appeals of a dentist denying input tax credits (“ITCs”) claimed in connection with certain expenses...more

Stikeman Elliott LLP

Tax Court of Canada Decision: Exclusions from the “Financial Service” Definition in Part IX of the Excise Tax Act Work As Intended...

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On July 19, 2022, the Tax Court of Canada (“TCC”) dismissed a major Canadian Bank’s appeal (the “Bank” or the “Appellant”) regarding the characterization of a supply made by the President’s Choice Bank (“PCB”) to the Bank....more

Stikeman Elliott LLP

GST/HST Input Tax Credit Claims: Does the Supporting Documentation Need to be Issued by the Supplier?

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On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more

Freeman Law

International Tax Treaty: Canada

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Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

Blake, Cassels & Graydon LLP

2019 Federal Budget – Selected Tax Measures

On March 19, 2019, the Minister of Finance introduced Canada’s 2019 federal budget (2019 Budget). The government had already signalled that the primary focus of the 2019 Budget would not be business concerns as those had been...more

Dickinson Wright

What Does a Business Setting Up in Canada Need to Know About Canada’s Tax Rules?

Dickinson Wright on

Canada’s tax rules are complex and subject to change. The information contained herein is not, and is not intended, to be a comprehensive overview of Canada’s tax system. Canada’s federal income tax system for businesses...more

Bennett Jones LLP

Bank Loan Repayments May Be Seized Due to Super Priority of Crown for GST/HST

Bennett Jones LLP on

On May 25, 2018, the Federal Court of Canada released its decision in Her Majesty the Queen v The Toronto-Dominion Bank. The case revolved around whether the proceeds of the sale of a house by a debtor of Toronto-Dominion...more

Blake, Cassels & Graydon LLP

2018 Federal Budget: Excise Tax on Cannabis

On February 27, 2018, the Minister of Finance introduced Canada’s 2018 Federal Budget (2018 Budget), which looks to implement the excise duty framework for cannabis that was proposed in November 2017 (see our November 2017...more

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